Most affected employers understand their obligations to comply with the Occupational Safety and Health Administration’s control of hazardous energy (commonly called “lockout/tagout”) rules found at 29 C.F.R. §1910.147. These regulations require employers to establish written plans and implement procedures to make certain that machines cannot operate during maintenance and other times when unanticipated energization could lead to employee injury.

Lockout/tagout violations are some of the most common citations issued by OSHA. Some employers are surprised to receive citations for failure to comply with these rules when they have implemented general policies and written plans intended to address energization safety issues. OSHA often cites manufacturers and other employers that fail to prepare lockout/tagout procedures for each individual machine. The hazardous energy control rules require such individualized plans, and general instructions on lockout/tagout procedures will not satisfy this requirement. In some cases, employers can justify a single policy for identical or very similar machinery, but in most situations, companies should develop plans specific to each machine’s hazards and de-energization requirements.

Employers are also sometimes surprised to receive lockout/tagout citations for operations that do not involve electrical or mechanical energy sources. Section 147 also applies to other forms of stored energy such as pressure, hydraulic lines, and other potential employee hazards. Failure to control stored energy continues to rank high among causes of employee injuries and death. Current and comprehensive lockout/tagout programs should be a key part of employers' safety compliance programs.

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